Archive for May, 2013

PDF – BACK TO THE DRAWING BOARD – Section by Section Analysis of Proposed CFC Regulations

Posted on May 24, 2013. Filed under: Combined Federal Campaign - CFC, Customer Service, Fundraising, Leadership, Non-profits, Office of Personnel Management (OPM) |

Back to the Drawing Board!-CFC ANALYSIS -by Bill Huddleston_Final

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Why Does the Combined Federal Campaign (CFC) Matter?

Posted on May 21, 2013. Filed under: Combined Federal Campaign - CFC, Fundraising, Leadership, Non-profits, Office of Personnel Management (OPM), Volunteer |

Why Does the Combined Federal Campaign (CFC)  Matter?

Why Does OPM Want to Kill the Golden Goose of American Philanthropy?

By Bill Huddleston, The CFC Coach

The Combined Federal Campaign (CFC) matters because through it, and the generosity of the hundreds of thousands of Federal public servants who are the CFC donors, millions of Americans and others throughout the world are helped by the actions and services provided by  the more than 25,000 non-profits that are enrolled in the Combined Federal Campaign.  In the fall 2012 campaign,  more than $258 million dollars were raised, and in terms of actual giving, if the CFC were a foundation, it would be the 14th largest foundation in the USA.   Over  the past five years, the CFC has generated more than $1 billion of unrestricted revenue for thousands of local, national and international CFC charities, which makes it the single largest source of unrestricted funds in the non-profit sector.

The CFC, which was established in 1960, is the federal government’s workplace giving program, and is administered by the Office of Personnel Management (OPM).  The CFC used to have both a vision statement and their mission statement  on the CFC Operations home page that were succinct and inspiring:

CFC Vision Statement:

A government that encourages and enables active employee participation in community and that fosters collaboration with business and the nonprofit sector to achieve this goal.

CFC Mission Statement:

To promote and support philanthropy through a program that is employee focused, cost-efficient, and effective in providing all federal employees the opportunity to improve the quality of life for all.

Sometime in the last decade, OPM removed the vision statement, and they seem to have forgotten what the mission statement really means, having just completed an analysis of the proposed changes to the Combined Federal Campaign regulations, that are massive and harmful to the CFC if implemented as proposed, but let’s first look at the present setup.

Workplace giving is a unique type of fundraising in the non-profit sector, and it’s important to understand the complex synergy that exists among all the parts.   In the current structure of Combined Federal Campaign, these are the major components:

  • Recipients of services from CFC Charities  – the people and other beneficiaries of the services provided by the 25,000 CFC charities. (Millions of people ).
  • CFC Donors  -The Federal Public Servants who are the CFC Donors (more than 800,000).
  • CFC Charities – The 25,000 non-profits that are enrolled in the CFC, including approximately 1500 that are national or international in scope, and about 22,000 local charities.
  • Federations – Federations are special types of CFC charities, consisting of groups of 15 or more charities with something in common, e.g. the member of Community Health Charities federation are all health related, EarthShare has environmentally oriented non-profits as its members, and the members of Children’s Charities of America deal with issues affecting children to mention just a few.  Federations can be national, international or local.  Federations assist their members with their CFC applications, provide joint marketing support, and provide other campaign related services.
  • U.S. Federal agencies , that conduct the CFC campaigns, and this means anywhere in the world where there is a US Federal installation, (including places like Afghanistan and Iraq) there is a CFC campaign, as well as all civilian, military and U.S. Postal service facilities in the U.S.
  • CFC Campaign Volunteers – The thousands of Federal employees who volunteer each year to help run their agency’s CFC campaign, solicit funds, organize charity fairs, and conduct the overall management of a campaign within a Federal agency.    When the CFC campaigns are conducted each fall, the CFC is the
  • CFCs are organized regionally, and currently there are 184 CFC regions:
    • Local Federal Coordinating Committee (LFCC ) Each region has a Federal “Board of Directors” called the LFCC that is responsible for reviewing and approving applications for local charities to enroll in the CFC; and it is responsible for the selection of the Principal Combined Fund Organization (PCFO) which are contractors to the government  and there is a one to one match, so currently there are 184 PCFOs.
    • Principal Combined Fund Organization (PCFO) has two major responsibilities: the overall management of the CFC campaign in its region; and the fiduciary responsibility of sending the CFC donors gifts to the CFC charities they designated.  PCFOs are 501(c) (3) non-profits.  In the 184 regions, the PCFOs in the larger areas (e.g. major metropolitan areas, and areas with large Federal installations (e.g. Army, Navy, Marine, Air Force, Veteran Affairs hospitals, Postal Service regional centers, etc.), have larger staffs than in the more sparsely populated regions.
  • Office of Personnel Management (OPM) has overall responsibility for the Combined Federal Campaign, including the CFC regulations and any appeals from non-profits that had their applications denied.   The OPM CFC office has a small staff of less than twenty.  It approves the applications of national and international charities, which currently number about 1500.
  • Federal Executive Boards (FEB) and Federal Executive Associations ( FEAs).   In areas outside of the Washington DC area, regional entities responsible for regional government wide operations, and often have the LFCC function as part of their responsibilities.
  • CFC-50 Commission  On the occasion of the 50th Anniversary of the CFC in 2011, there was a special commission formed that was chaired by two respected former Congressmen,  the Hon. Tom Davis (R) from Virginia and the Hon. Beverly Byron (D) from Maryland, each of whom had experience with the government reform committee when in Congress.  There CFC-50 Commission conducted a series of meetings, and issued a final report in July 2012 that contained 24 recommendations to OPM on ways to improve the CFC. 

 

  • Federal Retirees:  Retirees currently cannot have CFC designations deducted from their retirement pay, although the projections are that thousands of Federal retirees would participate in the CFC if they could.

CFC – The Golden Goose of American Philanthropy

 

When I give workshop presentations about the CFC, my workshop title is: “CFC—The Golden Goose of American Philanthropy.” I use that title because, just like the farmer in that fairy tale, most people do not understand how the CFC works; they just know it produces money for their non-profit, if they know anything at all about it. Depending upon their non-profit, it may produce a lot, or it may produce a little, and non-profit leaders are often not sure how it works, and what if anything they can do to improve their CFC results.  But just like the golden goose, the fundamental fact about the CFC is that it does work, and works well.  I’m not saying that it can’t be improved, but in the “results oriented” culture of today, the CFC , as it is currently structured, produces results that help millions of people every year, having generated $258 million in 2012.  And in, a miracle of government function, it actually has less red tape than almost any grant.

The synergy that exists among the component parts that I outlined means that in the current, decentralized structure, the workload is spread out among many different players, and that there are benefits to each.

Massive Proposed Changes to CFC Regulations by OPM

The Office of Personnel Management has proposed sweeping, and massive changes to the regulations governing the Combined Federal Campaign, and even though they say that they basing the proposed changes on the CFC-50 report, it many cases what they’re proposing was never discussed, or goes far beyond what was discussed in the CFC-50 Open Meetings and Final Report, or ignores what the CFC-50 Report recommended.

The proposed regulations are an odd combination of massive overreach; destruction of hundreds of private sector non-profit jobs in lieu of new Federal positions (which have not been approved or budgeted); hiding important sections in illogical sections of the proposed regulations, while simultaneously making multi-million dollar errors in the same section (in the section dealing with Federal retirees); making small irritating changes that are harmful to the CFC donors information gathering and make things harder for both the donor and the CFC charities; the destruction of multiple business models that have been successful for decades without adequate discussion,  and there are a few good ideas as well.   In many areas the proposed regulations are contradictory with significant differences about what the stated purpose is, and what the actual effect will be.

As proposed, the regulations are:

  • Harmful to CFC charities, both large and small, and will definitely drive smaller charities whether local, national, or international out of the CFC.
  • Harmful to CFC donors
  • Harmful to CFC Federations
  • Harmful to Federal agencies, including the leadership development of their workforce
  • Harmful to the non-profit employees of the PCFOs, where all 184 private sector organizations are eliminated which means that at least 450 non-profit jobs now go to Federal positions.
  • Harmful to the beneficiaries of the services provided by the CFC charities.  When just one of the items in the proposed regulations has been tried at the municipal or state level (going all electronic) there has been 50% drops in revenue.  If the regulations are implemented as proposed, a 75% drop in revenues is likely.
  • Presume a massive transfer of functions from the private sector, non-profit PCFOs to the Federal workforce.

Hidden Regulations – Federal Retirees Section

Some of the proposed regulations are poorly organized, with no logic behind them, and they have the effect of hiding significant and important changes.  For example, the section dealing with Federal retirees instead of being in a “Donors” section is hidden in the “establishing Regional Committees” section, ignores the CFC-50 Commission recommendations, and makes a multi-million dollar error in judgment, all in less than a paragraph.   Here’s the link to the section that deals with retirees, hidden in the phrase “and also eliminates restriction on soliciting non-Federal personnel.”   950.103 Establishing Regional Coordinating Committees.

I have posted my analysis of the proposed CFC Regulations on the CFCTreasures.wordpress .com site and on the SAVETHECFC Linked in site.  It’s  50 plus pages with the regulations links, OPM’s analysis, my analysis, and recommended actions in a table form.

 Federal Government Public Comment Period Closes June 7, 2013.

This is the bad news, the good news is that these are proposed regulations, and we are in the Public Comment Period, which closes June 7, 2013.  By law Federal agencies must put out proposed regulations for public comment, and they must respond to all issues raised before implementing the regulations.  This is your opportunity to affect public policy in a meaningful way, and to stop the regulations from being implemented as proposed.   I think the overall message is that the regulations as proposed are harmful, and OPM needs to go back to the drawing board.

There are two ways to comment:  Send a written letter to the OPM’s Director of the Combined Federal Campaign, Keith Willingham or submit your comments via the electronic comment function of the Federal Register.   My recommendation is to use the Federal Register method because other members of the non-profit community will also be able to see your comments.

Subject: RIN 3206-AM68, Solicitation of Federal Civilian and Uniformed Service Personnel for Contributions to Private Voluntary Organizations

Reference Number: RIN 3206-AM68

Dates:    OPM must receive comments on or before June 7, 2013

Here are the links to the proposed changes to the CFC regulations.

URL: https://www.federalregister.gov/articles/2013/04/08/2013-08017/solicitation-of-federal-civilian-and-uniformed-service-personnel-for-contributions-to-private

Shorter URL:   https://federalregister.gov/a/2013-08017

HERE IS THE SPECIFIC PAGE TO COMMENT ON THE PROPOSED CFC REGULATIONS: http://www.regulations.gov/#!docketDetail;rpp=100;so=DESC;sb=docId;po=0;D=OPM-2013-0006

Contact info for Bill Huddleston:

If you have questions or concerns about how you can help save the CFC as one of the most useful programs for millions of Americans who benefit from the $258 million dollars generated annually by the CFC, please don’t hesitate to contact me at BillHuddleston@verizon.net or by phone at 703-434-9780.

Email: billhuddleston@verizon.net

Phone: 703-434-9780

http://www.cfctreasures.wordpress.com

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HOW TO COMMENT ON THE PROPOSED COMBINED FEDERAL CAMPAIGN (CFC) REGULATIONS

Posted on May 14, 2013. Filed under: Combined Federal Campaign - CFC, Fundraising, Leadership, Non-profits, Office of Personnel Management (OPM) |

                MASSIVE CHANGES PROPOSED TO

                 COMBINED FEDERAL CAMPAIGN (CFC) 

WILL HARM NON-PROFITS IF IMPLEMENTED AS PROPOSED

By Bill Huddleston, The CFC Coach, billhuddleston@verizon.net, 703-434-9780

NON-PROFITS WHO CARE ABOUT THE SINGLE LARGEST SOURCE OF UNRESTRICTED FUNDS IN USA – THE COMBINED FEDERAL CAMPAIGN – PLEASE READ AND COMMENT TO SAVE THE CFC!

HOW TO COMMENT ON THE PROPOSED COMBINED FEDERAL CAMPAIGN REGULATIONS

The Office of Personnel Management (OPM) has proposed massive changes to how the Combined Federal Campaign works.  There are more than 40 pages of proposed regulations, and my analysis of the changes can be found at the SAVETHECFC Linked-In Group and on my blog at www.cfctreasures.wordpress.com.  There is a public comment period for all proposed government regulations, and the comment period concerning the Combined Federal Campaign proposed regulations closes June 7, 2013.

There are two ways to comment:  Send a written letter to the OPM’s Director of the Combined Federal Campaign, Keith Willingham or submit your comments via the electronic comment function of the Federal Register.   My recommendation is to use the Federal Register method because other members of the non-profit community will also be able to see your comments.

Subject: RIN 3206-AM68, Solicitation of Federal Civilian and Uniformed Service Personnel for Contributions to Private Voluntary Organizations

Reference Number: RIN 3206-AM68

Dates:    OPM must receive comments on or before June 7, 2013

URL: https://www.federalregister.gov/articles/2013/04/08/2013-08017/solicitation-of-federal-civilian-and-uniformed-service-personnel-for-contributions-to-private

Shorter URL:   https://federalregister.gov/a/2013-08017

Here’s one example of a proposed change that will have negative impacts on CFC charities,  the Federal CFC donor, and most importantly the people that receive the services from the many CFC charities.

 Example of a Proposed Regulation Missing the Mark with wide negative consequences:

“Shifting the Campaign” is NOT the same as “Extending”

In the CFC-50 Commission
meetings there were many people and organizations that spoke to the benefit of extending the campaign to January 15th from the current December 15th end.  There are many reasons for this, including both year-end charitable giving and federal personnel schedules.

In watching all eight hours of video testimony, reading all the recommendations and appendices in the CFC-50 report, not a single person said “Shift the Campaign” from September to December to October to January.    “Shifting” is not the same as “extending” and there are many negative consequences to shifting, which I will describe in detail in later posts, but since there was no mention of this at all in 4 public meetings over many months, the idea was not addressed.

Will Cut CFC Revenues in Half:

If implemented as proposed these untested changes will have the effect of cutting CFC revenues for thousands of CFC charities in half, which is what has happened when such massive changes have been tried at the in workplace giving campaigns at the city and state level.  To see how much revenue was raised in your state through the CFC, please see this worksheet I created showing the state by state totals. https://cfctreasures.wordpress.com/2013/05/02/combined-federal-campaign-2012-results-by-state

If you have questions or concerns about how you can help save the CFC as one of the most useful programs for millions of Americans who benefit from the $260 million dollars generated annually by the CFC, please don’t hesitate to contact me at BillHuddleston@verizon.net or by phone at 703-434-9780.

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COMBINED FEDERAL CAMPAIGN 2012 RESULTS BY STATE

Posted on May 2, 2013. Filed under: Combined Federal Campaign - CFC, Fundraising, Leadership, Non-profits |

Combined   Federal Campaign (CFC)
2012 RESULTS BY STATE
Note: All CFC monies are   unresticted
ALABAMA $5,987,002 NEBRASKA $1,497,137
ALASKA $1,406,798 NEVADA $752,622
ARIZONA $3,759,035 NEW HAMPSHIRE, VERMONT $958,917
ARKANSAS $1,160,469 NEW JERSEY $1,846,414
CALIFORNIA $16,986,872 NEW MEXICO $1,765,967
COLORADO $5,352,033 NEW YORK $4,425,540
CONNECTICUT $798,324 NORTH CAROLINA $5,456,346
DELAWARE $433,244 NORTH DAKOTA $422,146
FLORIDA $10,226,824 OHIO $8,095,316
GEORGIA $8,247,388 OKLAHOMA $4,245,444
HAWAII $5,764,902 OREGON $1,639,158
ILLINOIS $4,304,315 PENNSYLVANIA $4,937,918
INDIANA $1,390,976 RHODE ISLAND $1,054,066
IOWA $611,413 SOUTH CAROLINA $3,028,794
KANSAS $447,603 SOUTH DAKOTA $445,332
KENTUCKY $2,190,295 TENNESSEE $5,395,505
LOUISIANA $2,345,817 TEXAS $18,802,381
MAINE $396,980 UTAH $2,828,564
MARYLAND $7,642,681 VIRGINIA $9,749,833
MASSACHUSETTS $2,162,187 WASHINGTON $7,091,300
MICHIGAN $2,954,134 WEST VIRGINIA $731,943
MINNESOTA $1,100,954 WISCONSIN $1,043,972
MISSISSIPPI $1,521,899 WYOMING $256,830
MISSOURI $7,482,330 PUERTO RICO $1,243,784
MONTANA $600,557 Washington, DC Natl Cap   Area $61,616,748
(DC, northern VA, sub.   MD)
OVERSEAS   CFC – DOD  $  13,646,352 Defense Department Deployed Personnel
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Massive Combined Federal Campaign CFC Changes Proposed For Non-profits

Posted on May 2, 2013. Filed under: Combined Federal Campaign - CFC, Customer Service, Fundraising, Leadership, Non-profits, Volunteer |

Massive Combined Federal Campaign Changes Proposed For Non-profits

Most of the proposed changes are  bad – These measures Throw Out the Baby with the Bathwater, and toss the tub on top for good measure.

Bill Huddleston, The CFC Coach, said that “The proposed changes to the Combined Federal Campaign (CFC) regulations will have the effect of destroying the CFC for small non-profits, whether they are local or national.”

The CFC Regulations as proposed will not help CFC charities, donors, or the people the CFC non-profits serve.  In addition, huge areas of importance are not addressed at all in the proposed regulations, including the value of the CFC to the sponsoring agencies and their employees.

The regulations were published on April 7th in the Federal Register, and there is a 60 day comment period which ends June 7th.  In other posts I will show you how to use the Federal Register commenting software, but if you think the CFC is worth saving, now is the time to act!

Will Cut CFC Revenues in Half

As proposed, these regulations completely eliminate the face to face aspect of the entire CFC campaign. If implemented as proposed these untested changes will have the effect of cutting CFC revenues for thousands of CFC charities in half, which is what has happened when such massive changes have been tried at the in workplace giving campaigns at the city and state level.  To see how much revenue was raised in your state through the CFC, please see this worksheet I created showing the state by state totals.  (see separate post)

After 50 years of being the most successful workplace giving program in the world, and the single largest source of unrestricted funds for non-profits, these proposed changes “throw the baby out with the bathwater, and then toss the tub on top for good measure!”

Massive Changes Proposed Without Adequate Discussion

The changes planned the proposed regulations are gigantic, and the proposed regulations make mistakes along the classic “New Coke” marketing debacle, when after much discussion about how to improve Coke, classic Coke was pulled from the market, and the cry went up, “Wait, you didn’t tell us you planned to destroy Coca-Cola!”

That’s the effect these new regulations will have, they will destroy the CFC, which is the single largest source of unrestricted funds for non-profits in the US.   The proposed regulations contain an odd mish mash of sweeping changes with no specifics on how the changes will actually be accomplished, wipes out organizations that have been in existence for more than 50 years, and especially in time of sequestration, are divorced from reality, because in order to actually implement them, there would need to be ten times increase in the number of Federal employees working on the CFC.

CFC – 50 Commission

A little background is in order, the CFC celebrated its 50th Anniversary in 2011, and at that time the head of the Office of Personnel Management (OPM), John Berry,  formed a commission, called the CFC-50 Commission, to look at ways to improve the CFC and keep it vibrant for the next 50 years.  The Commission was chaired by two former members of Congress, Hon. Tom Davis, (R-VA) and Hon. Beverly Byron, (D-MD), each of whom is well respected in the Federal service, and had served on government operations committees during their Congressional tenure.

CFC -50 Commission Public Meeting Videos (on Youtube)

The CFC-50 Commission met in public meetings four different times, and videos of these meeting are available at opm.gov/cfc.  http://www.opm.gov/combined-federal-campaign/cfc-50-commission (see list of videos at bottom of page).

The videos are difficult to watch because they are not optimized for viewing, there are no captions identifying who is speaking, and the speakers usually don’t identify themselves.  Some of them have 10 minute spans where the sound is inaudible.   There was testimony by invited participants, e.g. representatives from some of the larger charities, etc.

CFC – 50 Commission Report – 24 Recommendations

The Commission then produced their recommendations in a report, “Federal Advisory Commission Report on the Combined Federal Campaign” in July 2012, which contained 24 recommendations.

http://www.opm.gov/combined-federal-campaign/cfc-50-commission/2012-report.pdf

Two Good Recommendations

Some of these 24 recommendations survived intact in the proposed regulations, and some of them are good and make perfect sense, such as the ones dealing with new employees and the one dealing with disaster relief charities.

Many Proposed Regulations Do NOT Follow the Recommendations of the CFC-50 Commission

Many of the proposed regulations simply miss the mark from what the CFC-50 Commission actually recommended, had no or inadequate discussion about how some functions would actually be accomplished, and others are petty, or petty and unconstitutional.

Example of a Regulation Missing the Mark with wide negative consequences:

“Shifting the Campaign” is NOT the same as “Extending”

In the CFC-50 Commission meetings there were many people and organizations that spoke to the benefit of extending the campaign to January 15th from the current December 15th end.  There are many reasons for this, including both year-end charitable giving and federal personnel schedules.

In watching all eight hours of video testimony, reading all the recommendations and appendices in the CFC-50 report, not a single person said “Shift the Campaign” from September to December to October to January.    “Shifting” is not the same as “extending” and there are many negative consequences to shifting, which I will describe in detail in later posts, but since there was no mention of this at all in 4 public meetings over many months, the idea was not addressed.

The Proposed Regulations can be found here:

https://s3.amazonaws.com/public-inspection.federalregister.gov/2013-08017.pdf.

In later posts, I will have information on how to use the Federal Register rule making portal to make comments.

Thanks,

Bill Huddleston

The CFC Coach

billhuddleston@verizon.net

703-443-9780.

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